PRIVACY POLICY provided pursuant to Legislative Decree no. 196/2003 (Italian Privacy Act) and EU Regulation no. 2016/679

In terms of the provisions of Legislative Decree no. 196/2003, the Italian Privacy Act, and EU Regulation no. 2016/679 (Art. 12 and 13 in particular), we would like to advise you that your personal data will be processed in accordance with applicable law.

ERREGAME SPA with registered address in Napoli, at Via Cesario Console 3, pledges to seek out and use the technical and organisational solutions needed to ensure high standards of lawfulness, security, and protection in terms of personal-data processing. The requirements of the European Union General Data Protection Regulation (hereinafter, “GDPR”) and other laws, the Italian Privacy Act (hereinafter, “Privacy Act” or “Act”) in particular have all been implemented.

The data controller is ERREGAME SPA with registered office at Via Cesario Console 3, Napoli, as defined under the GDPR and the Act.
Erregame s.p.a. may process any type of information relating to any identified or identifiable natural or legal person, as identified under Art. 4 of EU Regulation no. 2016/679.

Data supplied by our customers mean any information you have provided to offer to purchase a good and/or service. These data include but are not limited to: name and surname, contact information (address, telephone number, email address), occupation, place and date of birth, Tax ID number, VAT number, PEC [certified email address]. Submission of such data, if required by contract, or if essential to performance under the same, constitutes a requirement for executing that contract. Any failure to disclose such information may make it impossible to finalise the Contract and/or for Erregame s.p.a. to provide the product or service in question.

“Personal data” means any type of information relating to an identified or identifiable natural or legal person. We will process your data solely to the extent permitted by law. To wit, we will process your data pursuant to Art. 6 and 9 of the GDPR, and pursuant to your consent, as permitted under Art. 7 of the GDPR, in order to execute and thereafter perform under a contract you have solicited, and to discharge all tax-related duties.

You data will be processed by us exclusively for those purposes permitted by data-protection laws, including: a) purposes you have approved in advance; b) data processing to perform under the Contract; c) carrying out any pre-contractual requests you have made; d) discharging any statutory or regulatory duty incumbent on us; e) safeguarding our legitimate interests, or those of any third party, except in those instances where your interests trump ours or that of the third party; f) determining, asserting, or defending a legal right or claim; g) for significant public interests; h) for tax-related purposes.

We will process your data for reasons including the following specific purposes:
- Contract-related purposes, especially to perform under the Contract we have executed with you;
- to contact you regarding the Contract, and to manage the same;
- we will duly process your data to provide proper customer service, including, for example, to provide a more complete consultancy service;
- in order to allow for any requests relating to statutory warranties, product conformity, customer support, or requests to withdraw from, manage, or terminate the Contract.

Your data will be processed pursuant to Art. 5, paragraph 1, subpart (e), and shall be retained only for as long as needed to process the same for the stated processing purposes. If we process your data for more than one purpose, they will be automatically deleted, or saved in a format that does not allow for you to be immediately identified, as soon as the specific purpose has been reached.

Generally speaking, your data will be retained for the following periods:
- tax/administrative purposes: 10 years;
- statutory/regulatory compliance relating to product warranties: 28 months;
- contract duties relating to optional post-sales services: from 36 to 78 months depending on service selected.

Erregame spa will process your data pursuant to data-security regulations established by Art. 32 of the GDPR. In order to ensure a suitable level of data security aimed at mitigating the risk of improper or unlawful use of the same, certain technical and organisational measures which comply with international IT standards have been implemented. These measures are continually monitored to ensure compliance.

You data may be disclosed to third parties including but not limited to:
- parties within the Erregame spa Group, taking suitable care to ensure they will be processed, protected, and transferred in a legally compliant way.
- third parties to the extent such transfer is necessary or convenient in the discharge of any statutory reporting or disclosure duty, or for tax/finance compliance.

Such third parties shall include, to wit, IT service providers, outsourced consultants, associates, for the following purposes:
- envelope-stuffing, sorting, and sending customer correspondence, as well as for data archiving and alternative storage, and outgoing merchandise shipments;
- providing and managing financial and IT systems, communication network access, and safety/security systems;
- customer support services (including call centres and help desks);
- expert opinions, external auditing, and financial-statement certification;
- professional consultancy and support

ERREGAME SPA shall duly appoint such parties as Data Processors, provided the requirements for the same are met, or shall otherwise require that such parties undertake a duty of confidentiality with respect to your data.
Erregame spa pledges not to transfer your data outside the European Community.

You may, pursuant to the GDPR and other applicable data-protection provisions, fully assert your rights relating to any data in our possession. To wit, you may request that information on data in our possession be provided to you at any time. This information may refer to, inter alia, categories of data processed by us, processing purposes, the source of data (if not obtained directly from you), as well as the recipients to whom we might transfer you data, if any.

You may request a complimentary copy of the data subject to the contract.

Pursuant to Art. 16 of the GDPR, you may request your data be rectified. We will take all suitable measures to ensure that any of your data in our possession, processed on an ongoing basis, is accurate, complete, updated, and relevant, based on the most recent information we have been provided.

Pursuant to Art. 17 of the GDPR, you may request your data be erased insofar as permitted by law, and without prejudice to any tax-related or other statutory retention periods incumbent upon Erregame spa.
You have the right to a copy of the data supplied directly by Erregame spa. Upon your express request, we agree (insofar as technically feasible) to transfer your data to another data controller, identified by you.

You may object at any time, for reasons relating to your specific circumstances, to the processing of your data pursuant to Art. 6, paragraph 1, subparts (e)-(f) of the GDPR, to our continuing to process your data. This latter rule shall not apply if we can state cognisable, legitimate interests which justify our processing the data, and which trump your own, or if we otherwise need your data to determine, assert, or defend a right in a court of law.

Should processing be predicated on consent (and without prejudice to the lawfulness of any processing predicated on such consent prior to revocation) you may revoke consent by sending a request to us using the contact information appearing above.
Erregame spa will use its best efforts to manage all requests within a reasonable period, generally within thirty (30) days, unless a justified reason for extension, duly identified and communicated to you, arises.

You have the right, at all times, to report and lodge a complaint with the data-protection authorities pursuant to Art. 77 of the GDPR. For more information on privacy laws, please visit the Data Protection Authority website at www.garanteprivacy.it

The data controller is Erregame s.pa., acting by and through its Legal Representative, who may be reached at: Via Cesario Console, 3, 80132 Napoli.

For informational enquiries, or to assert your rights please contact ERREGAME SpA:
- via regular post at: ERREGAME SPA, Via Cesario Console, 3, 80132 Napoli;
- by telephone: +39 081/757.42.85
- via fax: +39 081/540.01.15
- by email: info@erregamespa.it

The Data Protection Officer may be contacted directly at info@erregamespa.it

Erregame s.p.a. Should any substantive changes occur with respect to how your data are being processed, we will notify you promptly.